Some of the changes are aimed at addressing existing problems for sponsored carers and senior carers, as well as ending 'self-sponsorship' of business owners under the route. More broadly, various changes to salary-related rules will have the effect of increasing the amount that workers must be paid to qualify for sponsorship.
The Home Office published a new Statement of Changes in Immigration Rules HC 733 on 12 March 2025, incorporating changes to the Skilled Worker route from 9 April 2025. We expect corresponding Home Office guidance to be published on 9 April 2025.
Salary threshold increases
Several changes to the salary requirements are outlined below.
Increase to general salary threshold and certain occupation-based going rates
The lowest general salary threshold will increase from £23,200 per year (or £11.90 per hour) to £25,000 per year (or £12.82 per hour). A Skilled Worker will be affected if:
- They are making a Skilled Worker application and have previously been sponsored with a Certificate of Sponsorship (CoS) assigned before 4 April 2024 and scored points for having a PhD in a STEM subject, a job on the Immigration Salary List, or being a new entrant at the start of their career; or
- They are sponsored for a job in a listed health or education occupation (this includes Skilled Workers who are already sponsored and those new to the Skilled Worker route); or
- They are applying for settlement and scored the points for their most recent permission for a job on the Immigration Salary List (or the previous Shortage Occupation List) or for a job in a listed health or education occupation; or
- They are applying for settlement incorporating time spent as a Tier 2 (General) worker sponsored for certain science or teaching jobs.
The Home Office states it is standard practice to update the salary requirements using the latest Annual Survey of Hours and Earnings (ASHE) data from the Office for National Statistics (ONS). This helps reflect the latest pay situation for UK workers and allows workers to be paid fairly.
Because of the general minimum salary increase, occupation-based going rates that are lower than £25,000 per year (£12.82 per hour) will also be updated.
Increase to salaries in health and education occupations
The going rates for health and education occupations are being revised based on updated national pay scales.
NHS Employers have flagged that the increase to the general minimum salary threshold means that entry-level Band 3 roles will no longer be eligible for international sponsorship. Public sector healthcare employers will need to wait until the Agenda for Change 25/26 pay award is announced to determine if Band 3 will be above the £25,000 salary threshold.
Further salary increases may be in the pipeline
The Explanatory Memorandum to HC 733 suggests this isn't the end in terms of salary rises. The Government will shortly publish an Immigration White Paper, which may include more significant salary rises across work routes.
We'll be providing further information as it becomes available, and you can sign up to receive our updates here.
New rules excluding deductions, loans and investments from qualifying salary
The Home Office is introducing new Rules excluding salary deductions, loans to workers and investments made by workers into the sponsoring business from being counted towards meeting Skilled Worker salary thresholds.
These apply to Certificates of Sponsorship assigned on or after 9 April 2025.
What are the new Rules?
The new Rules will require the salary being relied on for a Skilled Worker application to be reduced where the applicant pays money to their sponsor or a related organisation and this is deducted from their salary, repaid as a loan or is made as an investment.
The salary will not be reduced where the payment is not related to business costs, immigration costs or investment, but has the character of being an additional benefit, which the applicant has a genuine choice to take. Examples of such deductions may include salary sacrifice arrangements, which are usually offered to everyone, not only to sponsored workers.
The calculation will be made by averaging the amount the worker is due to pay to their sponsor over the length of their sponsorship.
As a reminder, a sponsor cannot pass on certain immigration-related costs to a sponsored worker. See our previous article for more details.
Why is this happening?
The Explanatory Memorandum states these changes are being made:
- For consistency with how paid allowances for the same purposes are treated;
- To mitigate against sponsorship costs being passed on to applicants; and
- To close an unintended loophole whereby applicants could effectively pay towards their own salary through investing in their sponsor's business (sometimes referred to as 'self-sponsorship)).
What does this mean in practice?
To be eligible for Skilled Worker sponsorship with a CoS issued on or after 9 April 2025, a worker's proposed salary must meet the salary thresholds after a recalculation is made to deduct any relevant payments by the worker to the sponsor.
The new rules are drafted widely, especially as regards deductions and investments. We expect that further detail will be included in Home Office guidance, and that other policy clarifications will need to be made.
We are monitoring developments and will provide further commentary as new information becomes available. You can sign up for updates here or contact a member of our immigration team for advice on specific arrangements.
Qualification restriction on eligibility for new entrant salary discount
A change is made to specify that an applicant seeking to rely on the new entrant salary discount due to training for a recognised professional qualification will only be able to do so if this is a UK qualification.
New recruitment requirement for sponsors of care workers
New Rules will require care provider sponsors in England to demonstrate they have attempted to recruit carers or senior carers from within the country who no longer have sponsorship (for example where their sponsor's licence has been revoked, or their sponsor has insufficient work hours for them) before being allowed to sponsor individuals switching from other immigration routes or from abroad.
The sponsor must provide evidence that they have attempted to recruit from the relevant regional or sub-regional partnership, and confirm that there were no suitable workers available from this pool.
The requirement will not apply to in-country Skilled Worker applications made by individuals who:
- Were last granted immigration permission as a carer or senior carer under the Skilled Worker route; or
- Are switching to Skilled Worker from another immigration route, and have already been working lawfully for their sponsor as a carer or senior carer for at least three months ending on the date of their application.
Need more help?
For a broader discussion of these developments and other recent and upcoming immigration law changes, sign up to our next What's Happening in Immigration Law session on 26 March.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
